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Chemicals Coffee Time, 6th September 2024

Posted06/09/2024
Updated05/09/2024
Byghsclassif1stg

Dear {{ subscriber.first_name }},

Happy Friday!

It’s definitely autumn here, as the rowan trees are heavy with fruit, so Mike is preparing to make some rowan and apple jelly (guess what this week’s recipe is?). And to go along with the “​mellow fruitfulness​“, we have the mists as well, some days the mist has hardly lifted at all.

Speaking of mists clearing, some news from the EU with an important clarification:

Breaking news – EU-CLP corrigenda approved by ENVI committee

Huge thanks to ​Aaron McLoughlin​ who has shared this news on LinkedIn, see ​https://www.linkedin.com/posts/aaron-mcloughlin-1a86281_meeting-agenda-updates-activity-7237035695322599425-siji​ .

Thanks also to everyone else in industry and chemical trade bodies who emailed me about this too – I really appreciate you taking the time to let us know, and “better to hear twice than not at all”. We have such a lovely group of readers, I’m very grateful to you all.

The corrigendum document is at ​https://www.europarl.europa.eu/meetdocs/2024_2029/plmrep/COMMITTEES/ENVI/DV/2024/09-04/2022_0432_COR01_EN.pdf​ which I have definitely NOT read in Ali’s absence.

A reader writes: I haven’t had chance to read the whole text, but did look at Article 2 and the application dates – the references to the parts which caused the confusion with the application dates – this has been amended – formatting for fold out labels is brought in after 18 months (now point (4) not (3b), the other label formats after 2 years. Changes to Annex VIII now in Annex IV and also apply after 2 years, as Article 2 (3) now refers to Annex IV.

Jan Robinson of AISE also writes:

The two content changes I immediately spotted were in Article 48 (the additional statement for consumers has been shortened slightly – some might not consider that substantive though) and in Annex I section ​1.2.1.6​ (additional elements added to the front page of a fold-out label – possibly correcting an accidental omission from the provisional agreement text?). I’d be delighted to hear of any others that your readers noticed! Overall it’s nice to have a version of the text where at least the numbering etc. is fixed, although it’s not completely free of typos (e.g. “eproductive toxicity” in Annex II 😀). Unfortunately the transitional provisions have not been made a lot easier to read/understand – that would have been a plus!

Many thanks to our readers for spotting this. It’s really good to get the timelines sorted out. If you have the time to go through this and see any other significant changes, please let me know and I will include it in another newsletter. (While Alison is off, I don’t have time to go through this, and usually she reads the small print on documents like this for me!).

Hearing from the HSE and the UK

HSE surveys

There are (at least) two important surveys from the HSE asking for industry’s help, mainly via the Trade Associations (hat tip to CBA and BCF for letting us know about these).

Firstly, there is a survey on UK-REACH fees which has been sent to various trade bodies. The proposals are here: ​REACH fees stakeholder engagement note – August 2024.pdf​ and here: ​Annex A Proposed revised REACH fees table.pdf​ , and you should feed your comments back ASAP to your own trade organisation (eg CIA, CBA etc), as the consultation closes on Monday 16th September.

Members of the Chemical Regulations Self Help Group who are not members of a trade body may feed their comments back to Elaine McGavin at the CBA via her email: ​elaine.mcgavin@chemical.org.uk​ . Many thanks to Elaine for helping us out, particularly while Ali is away on sick leave.

Secondly, there is a survey on GB-CLP, and the HSE write:

HSE is looking for feedback on the current GB CLP Regulation

This is driven by internal improvements, changes to international legislation and revisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS).

We are collecting operational data from active participants in the GB CLP supply chain and would value your feedback on how the current GB CLP system is working and what impact any changes may have on your business and sector.

The voluntary survey is aimed at manufacturers, importers, downstream users and distributors in GB and Northern Ireland.

We are particularly interested in your feedback on:

  • notification (not relevant for downstream users and distributors)
  • relabelling
  • label formatting
  • chemicals under pressure
  • explosives not in transport configuration
  • ‘Keep out of reach of children’ pictogram
  • precautionary statements

The information you provide will be used by HSE to understand the impact of potential changes to GB CLP and develop impact assessments and future consultation exercises.

None of the information you provide will be used for regulatory inspection purposes.

The survey should take no longer than 15 minutes to complete and will close at 11:59pm on Wednesday 18 September.

​Complete the GB CLP Regulation survey​

Biocides

If you are on the HSE’s Biocide mailing list, you may have received a stern email on Wednesday about the number of biocides which are due to be withdrawn from the UK marketplace, see ​https://content.govdelivery.com/accounts/UKHSE/bulletins/3b1cef2​ . As usual, you need to download the data in excel form from this page: ​https://www.hse.gov.uk/biocides/uk-article-95-removal-list.htm?​

Some interesting statistics – there are a total of 2727 biocide/ product type/supplier combinations, which sounds like a massive amount; although it does break down to 114 individual substances across 630 suppliers (or 4.3 substances per supplier on average).

If you are unsure whether a biocide you are using is being supported by your supplier past the 3rd March 2025, you can check from the spreadsheet. I know that biocide suppliers will be waiting to see if there is sufficient demand for their products to re-register them, but if enough end users express interest then that should help retain as many biocides on the market as possible.

Notice to exporters – customs declaration service

If you export from GB, there’s been an update about the Customs Declaration Service, see ​https://www.gov.uk/government/publications/notice-to-exporters-202419-customs-declaration-service-cds-exports-important-information​

Keeping an Eye on ECHA and the EU

Poison Centre update

The latest edition of the document showing which Member States have adopted the Poison Centre Notification Portal has just landed. Bulgaria is the only country which has not joined yet:​https://poisoncentres.echa.europa.eu/documents/1789887/5674408/msd_en.pdf​ .

As usual, if you are making EU Poison Centre Notifications, I strongly recommend you join their LinkedIn group: ​https://linkedin.com/groups/12364138/​, run by the lovely Heidi Raasikari.

Even more SVHC proposals

Phil Rowley has spotted that on the 30th August, ECHA published another chunk of SVHC proposals, see ​https://echa.europa.eu/substances-of-very-high-concern-identification​ .

The affected chemicals (with reasons for SVHC proposal) are:

  • 6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acid, CAS no 2156592-54-8 (reprotoxin)
  • O,O,O-triphenyl phosphorothioate, CAS no 597-82-0 (PBT)
  • Octamethyltrisiloxane, CAS no 107-51-7 (vPvB)
  • Perfluamine, CAS no 338-83-0 (vPvB)
  • Reaction mass of: triphenylthiophosphate and tertiary butylated phenyl derivatives, CAS no 192268-65-8 (PBT)
  • Tris(4-nonylphenyl, branched and linear) phosphite, no CAS or EC number (Endocrine Disruptor, environment)

As usual, if any of these substances are in your portfolio or you have any data on them or simply want to comment, the HSE recommends you comment to ECHA in the first instance, as they will review ECHA’s decision before moving on to any local comments made direct to them.

Can you help ECHA?

ECHA asks for help with developing new methods ​https://www.linkedin.com/posts/heidi-rasikari-57b752188_chemicalsafety-echascience-activity-7234794947466416129-J0Ez​

Chemical snippets

Process safety corner

Recent incidents:

Some notes on Management of Change from Louise Whiting, including a reminder that once we have HAZOP’d a plant, it is assumed to be in a state of no change: ​https://www.linkedin.com/posts/louise-whiting_engineering-chemicalengineering-processsafetywithlouise-activity-7235175787841146880-peJf​

Jobs update (UK stats from LinkedIn)

Regulatory affairs, 1,546 jobs; Health and Safety, 992 jobs (but search on manager, specialist, officer etc as well, as the LinkedIn algorithm is still playing up). Nerd note – a job called “product safety” also popped up during this search, so it’s worthwhile searching on as many variations of job titles as you can think up.

An excellent Regulatory Affairs job at Arxada, ideal for someone based in the UK: ​https://lsi.wd3.myworkdayjobs.com/en-US/Arxada_Careers/details/Regulatory-Affairs-Specialist_R51902​

Infographic of the week

I hadn’t heard of the Spotlight Effect, but it’s that feeling of dread about being the centre of attention which any introvert/ nerd is well aware of. Details, and some tips on how to deal with it, from Tanmay Vora: ​https://www.linkedin.com/posts/tnvora_sketchnotes-ideasdrawn-unconsciousbiases-activity-7233781220730388480-RPcO​

The Weekend Read

Another excellent graphic novel from Rahmin Abhari, this time on the Bhopal disaster: ​https://www.linkedin.com/pulse/butterflies-bhopal-ramin-abhari-p-e–htawc​

Event update – CLP Mastery start date changed

While Mike’s busy cooking, and Ali is unfortunately away on sick leave, Grace and I have been busy reviewing the results of a live online course we ran in August, an introductory course on classification, labelling and SDSs called CLP Mastery Fastrak.

It was very interactive, with pre-printed workbooks to fill in as we went through the course, me in front of a whiteboard on camera doing my best to write clearly, and everyone was able to compile a reasonable CLP label by hand, and an SDS – all this after only about 8 hours together (2 1/2 hours per day over Tues/Weds/Thurs, with a follow up the following Wednesday).

Of course, it’s an introductory course, and there is much more for our lovely trainees to learn, but it’s a good starting point if you run software or need an outline for how the regulations work and how to put the communication documents together.

It also gave us immediate feedback on which exercises worked, and which didn’t (not all of them did, but we altered things for the next session). Thank you to everyone who attended, I know that Ali, Grace and I learned a lot too.

The key thing that I’ve learned is that we can build on our reverse-engineering of CLP, and apply that to SDSs as well, meaning that everything will be on a template basis, so you can fill in forms as you go to get the data you need (and alter it in the future).

This means we will be also able to run “full” CLP Mastery in a workshop style training similar to what we’ve just done for CLP Mastery Fastrak, and reduce the training phase from 13 weeks to 7 weeks. In order to

If you are interested in CLP Mastery (now starting in early October), please drop me an email – I’m really excited about it!

The Weekend Recipe

Rowan jelly, from the Scots Kitchen by F. Marian McNeill

Gather your rowan berries when almost ripe. Remove the stalks and wash and drain the berries. Put them in a preserving-pan with enough cold water to float them well. Let them simmer for about forty minutes or until the water is red and the berries are quite soft. Strain off the juice, being careful not to press the fruit in the least. Measure the juice and return it to the pan. Add sugar in the proportion of a pound to each pint of juice. Boil rapidly for half an hour or until some of it sets quickly on a plate when cold. Skim it well, pour it into small pots, and tie down quickly.

If you allow pound for pound of apple juice to rowan juice you will get a delightful jelly. Allow a pound of sugar to each pint of apple juice.

As rowans are quite bitter and tannic, I think using eating apples is a good idea. If I recall correctly, Mike cooked the apples in the same pan as the rowans, which meant only straining one set of juice, and this worked really well. Don’t worry if the juice is a little cloudy, it usually clears when boiled up with sugar. Don’t forget to dissolve the sugar in the juice over a low heat, before boiling quickly until it gets to setting point. Boiling it before the sugar is completely dissolved is likely to lead to crystallisation during storage.

Obscure fact of the week

Did you realise quite how much car sizes have increased? Mike and I often comment that the current “Mini” is actually a “Midi” or even a “Maxi” (for younger readers, three lengths of skirt fashionable in the 1970s).

A fascinating video shared by Grunde Jomaas: ​https://www.linkedin.com/posts/grunde-jomaas-43149a86_future-insurance-fire-activity-7235255548084948992-bAXB​

Reasons to be Cheerful

It’s been quite a week here for us at TT Environmental, so I thought a longer comedy compilation might be in order – it’s Peter Kay’s best ever bits: ​https://www.youtube.com/watch?v=2ZayKm_3h14​

Many thanks for reading this newsletter, and many thanks to everyone who has contributed to it this week. As usual, if you have anything you’d like to share, please email me and I’ll do my best to include it in the next newsletter.

I hope you have a good day today, and a lovely weekend with your family and friends. Take care, stay safe and I hope to be able to write to you next week.

Kind regards,

Janet

Janet Greenwood

TT Environmental Ltd

01422 24 22 22 07900 21 21 26 ​janet@ttenvironmental.co.uk​ ​www.ttenvironmental.co.uk​

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